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CIOT flags non-dom uncertainties

In a proactive and detailed submission the CIOT highlights various issues related to the non-dom reforms ‘that may require legislative change and other areas of uncertainty’.

On the foreign income and gains (FIG) regime consideration should be given to allowing individuals to make claims where they have inadvertently or carelessly failed to identify an item of foreign income or gains suggests the Institute – or potentially looking at making relief the default position (noting certain complications with that approach).

Provisions covering how relief is given for both income tax and CGT ‘are not as clear as they might be’ with clarification sought in guidance or as required by changes in the legislation. Various questions are also raised on the application of FA 2025 Sch 12 (trusts etc).

In section 4 of the paper the CIOT highlights (and discusses in detail) two ‘overriding issues with...

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